IV. Other Issues

Several parties raise issues, in filed comments and at the PHC, that are outside the scope of this rulemaking. We find no basis for expanding the scope of the proceeding to consider those issues.

SDG&E objects to the preliminary scope of this proceeding, because it asserts implementation of SB 1755 requires resolution of additional issues. Specifically, SDG&E requests that this proceeding ensure power generated under the authority granted by SB 1755 be used for the Districts' own purposes and constructed facilities meet safety and reliability standards and other applicable regulations. SDG&E further requests that responsible costs include public purpose programs, nuclear decommissioning, fixed transmission amount and restructuring implementation. SDG&E also raises concerns about its interconnection obligations and distribution planning. ACWA echoes the concerns about interconnection, stating it has never been able to arrange wheeling and comply with interconnection requirements when generation is located at a site different from where electricity is consumed.

SB 1755 limits use of power generated by the districts for their own pumping, water treatment, barrier intrusion, desalination and other operations. (Cal. Water Code §§ 31149.7(b), 71663.5 (b).) Although districts may sell surplus power to entities engaged in the distribution or sale of electricity, they may not sell power at retail. We need take no action to implement these statutory limitations. Further, proposed projects must conform to existing regulations and procedures, including, for example, interconnections rules. The approval processes for those projects will ensure conformance with those regulations and procedures. Finally, transmission and distribution rates include recovery for public purpose programs, nuclear decommissioning, and other charges. There is no need to address recovery of those items in this proceeding.